The Centers for Medicare & Medicaid Services (CMS) has announced the creation of a new voluntary advanced alternative payment model called Bundled Payments for Care Improvement Advanced (BPCI Advanced). Under the BPCI Advanced model, participants will take on financial risk for a 90-day clinical episode with a single retrospective bundled payment. CMS has determined the model qualifies as an advanced alternative payment model under the requirements of the Medicare Access and CHIP Reauthorization Act for the purposes of payment incentives under the physician Quality Payment Program. The attached request for applications includes additional information on the model, and CMS will hold an open door forum with a question and answer session on Jan. 30 from 9-10 a.m. (PT). Registration is open on CMS’ website.

Episode initiators must be participating acute care hospitals or physician group practices. In addition to the 29 inpatient clinical episodes included in the previous BPCI model, CMS has added three outpatient episodes identified by 30 Healthcare Common Procedure Coding System codes. Participants must select the clinical episodes for which they will be held financially accountable and will not be able to add or drop clinical episodes unless expressly permitted to do so by CMS.

The BPCI Advanced Model participation agreement will terminate on Dec. 31, 2025; the model’s performance period is Oct. 1, 2018 to Dec. 31, 2023. CMS has determined the model will be available for Quality Payment Program incentives beginning in performance year 2019. Applicants that wish to be considered for model participation beginning Oct. 1, 2018, must submit their application no later than March 12 by 8:59 p.m. (PT). The application portal will be accessible on CMS’ Innovation Center website beginning Jan. 11.

CHA notes that hospitals in voluntary Comprehensive Care for Joint Replacement (CJR) model markets must elect their continued participation in the program by Jan. 31. CHA encourages hospitals considering continued CJR participation — as well as those currently in alternative models that do not qualify for the Quality Payment Program as an advanced payment model — to carefully evaluate the BPCI Advanced model, as it may be more attractive to their physician partners. CHA encourages members to send questions about the BPCI Advanced Model directly to CMS at BPCIAdvanced@cms.hhs.gov.

Alyssa Keefe is responsible for policy development and analysis of federal regulation impacting California hospitals and health systems, and serves as a liaison between CHA and federal agencies, including the Centers for Medicare & Medicaid Services.